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DELPIT v. COMMISSIONER

Docket No. 6388-87.

63 T.C.M. 3053 (1992)

T.C. Memo. 1992-297

Larry D. Delpit and Dorothy D. Delpit v. Commissioner.

United States Tax Court.

Filed May 19, 1992.

Attorney(s) appearing for the Case

Jerry W. Carlton, 610 Newport Center Dr., Newport Beach, Calif., and John F. Daum, for the petitioners. John Kent and Marlene Kristovich, for the respondent.

Supplemental Memorandum Opinion

PARR, Judge:

These proceedings are under Rule 155.1 The opinion of this Court, in which we found petitioners liable as transferees under section 6901, was filed on April 2, 1991, as T.C. Memo. 1991-147. Petitioners have objected to respondent's computation under Rule 155, and have proffered their own computation. We find petitioners' arguments without merit...

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